The newly-posted episode of Mr. Watchlist’s DesigNation is about yesterday’s OFAC enforcement action against Comtech Telecommunications and Comtech EF Data. All you need to know: egregious violations, settlement larger than the base penalty, and only 1 mitigating General Factor… Hoo boy! What fun!
Let me start by saying “oh, my.” Four egregious violations, thankfully self-reported. The base penalty was $584,386 but the resulting fine was $894,111. What Happened On or about February 12, 2014, EF Data and Memotec, Inc. (“Memotec”), a wholly owned subsidiary of EF Data located in Montreal, Canada, prepared a […]
Time for some quick, kind of snarky commentary on the 2 settlements Deutsche Bank agreed to with OFAC last week. And one of them is basically a rerun of their 2013 action (let’s be kind, and say it’s more of a knock-off). Happy Listening – remember you can find the […]
OFAC Enters $583,100 Settlement with Deutsche Bank Trust Company Americas for Apparent Violations of Ukraine-Related Sanctions Regulations and Executive Order 13685 of December 19, 2014, “Blocking Property of Certain Persons and Prohibiting Certain Transactions with Respect to the Crimea Region of Ukraine” Deutsche Bank Trust Company Americas (DBTCA) agreed to […]
Memorandum of Understanding between OFAC and the State of Delaware Department of Justice; Inflation Adjustment of Civil Monetary Penalties Related to Reporting and Recordkeeping Release date 09/02/2020 Body Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the State of Delaware announced a Memorandum of Understanding setting […]
A short ode to OFAC’s General Factor J, and a quick, jaunty look at yesterday’s $5,000 OFAC settlement with “an individual.” Listen to it here… thanks!
Today, we shall start at the end and work backwards, more or less… today’s lesson? All U.S. persons, including members of the military and civil service stationed abroad, should exercise caution before voluntarily engaging in relationships with foreign persons that the U.S. person knows, or reasonably should know, may have […]
So, what happened? Between November 2012 and December 2015, Whitford and its owned or controlled foreign subsidiaries appear to have violated the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), 74 times when (1) Whitford’s foreign subsidiaries exported goods to Iran and engaged in trade-related transactions with Iran1; […]
The recent enforcement action against Essentra FZE also come with a settlement agreement. However, although a link is posted on the Recent Actions page, you can’t get to it from the list of enforcement actions OFAC maintains. The settlement is posted below – and adds some additional detail of the […]
Published today on KYC360, Amazon: Prime Time for Penalties is my latest. It goes beyond the facial failures and tries to dig a little deeper – like, why did they not catch references to Yalta? Did they not have geographic place name data? Was the reference in a data element […]